Clearly far too much has been said on this subject. Why more? This is the OWL perspective.

Very few people can claim to have been unsurprised by the referendum result. That level of surprise has created much of the current market disruption that we are experiencing. That disruption has created a climate of uncertainty bordering on fear. Much of it is irrational and sadly we have not seen the end of Project Fear.

While the big picture is primarily about sovereignty and immigration, the business picture is about the Single Market. And as we all know from endless missives in the past, the Single Market is made up of a series of passports, each designed in a slightly different way, largely depending on the age of its parent directive. How much is the UK financial services industry dependent on passports?

First, enormous numbers of regulated firms have no passports at all. For them the Single Market means European regulation without benefit. They get the pain, but all the gain goes to others. If UK regulation ceases to be driven by Brussels, these firms can look forward to seeing the back of obscure and dissipated regulation, written in often impenetrably poor English and driven by countries with no discernible financial services sector and no skin in the game. We shall move away from Commission-driven directives and regulations, drafted by civil servants who are not professional regulators, and into the domestic sphere where, like them or loathe them, the FCA makes the rules, after consultation and with full ability to amend and waive as necessary.

But not all firms survive in that happy state of innocence. Many are enmeshed in passports that take them around the Continent. Learned lawyers have written much on the detailed consequences of the loss of passports. Clearly we do not know whether any semblance of the passport will survive, but we should look at the worst case scenario.

An interesting development is the enthusiasm with which passports are now hailed. Consider AIFMD. Did you ever meet a person who would tell you what a great idea it was? How marvellous to have that passport for hedge funds, for NURSs, even apparently for closed-enders. No, there were no takers – AIFMD was roundly cursed. And what of the UCITS management passport? When FSA was involved in negotiations, the industry was most un-keen. And MiFID? The MiFID II were the fan club. Basically, we don’t like change.

And why were the American banks so keen on Remain? Could it just be that they enjoy competing at home and all over Asia with a UK industry that is shackled by EU regulation? EU firms must apply the Remuneration Code all over the globe; for others it bites only when they operate inside the EU.

Look at the opportunities. Despite their impeccably protectionist credentials, the EU has never totally managed to shut out the world. There will be much ‘equivalence’, better established here than anywhere. As a third country, the UK will be at the front of the queue. Project Innovate will have nothing on the dazzling scope for domestic and global products and services. Faced with a blank sheet, the FCA will invite the industry to fashion the regime of the future.

Of course there is adjustment to be made. Of course we will have challenges on the way. But, if we are brave enough to walk out of the unlocked cell, we will be able to wear our own clothes again.